IR 05000361/1982009
| ML20049K049 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/02/1982 |
| From: | Book H, Cillis M, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20049K043 | List: |
| References | |
| 50-361-82-09, 50-361-82-9, NUDOCS 8203290350 | |
| Download: ML20049K049 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION Report No. 50-361/82-09 Docket No. 50-361 Licensee No.
CPPR-97 Licensee: Southern California Eidson Company P. O. Box 800 2244 Walnut Grove Avenue
_Rosemead, California 91770 Facility Name:
San Onofre Unit 2 Inspection at: San Onofre Site,~ San Diego County, California
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Inspection Conducted: January 25 - February 12, 1982'
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Inspectors:
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M. Cillis, Radiation Specialist Date Signed
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fJL F. A. Wenslawski, Chief, Reactor Radiation D6te' Signed Pro ection S ction Approved by:
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/d'2 F. A. Wenslawski, Chief, Reactor Radiation Dafe Signed l
Pr ection Section Approved by:
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H. E. Book, Chief, Radiological Safety Branch Date Signed Inspection Summary Inspection on January 25-February 12,1982 (Report No. 50-361/82-09)
Aj eas Inspected: Routine announced preoperational inspection which included a to'ir of facilities, action on IF Circulars, and an examination of licensee action on previous inspection findings in regards to the status process and effluent radiation monitoring systems and the radiological environmental monitoring prrgram prior to the issuance of an Operating License (0.L.).
The inspection involved 71 hours8.217593e-4 days <br />0.0197 hours <br />1.173942e-4 weeks <br />2.70155e-5 months <br /> of on site time and 79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br /> of followup inspection effort at the Regional Office by two NRC inspectors.
Results:
No items of noncompliance or deviations were identified. Agreements were reached by SCE, NRR (ETSB) and the NRC Regional office for implementation of the licensee's process and effluent monitoring systems, radiological environmental monitoring program and a Quality Assurance program for effluent and environmental monitoring to support issuance of an operating license for the facility.
8203290300 820302 PDR ADOCK 05000361
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DETAILS
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Persons Contacted Southern California Edison Company (SCE)
- H. B. Ray, Station Manager
- +W. C. Moody, Deputy Station' Manager
- +0. E. Nunn, Project Manager T. Elkins, Startup Engineer
- T. Garvens, Lead Quality Assurance Engineer
- B. Katz, Station Technical ~ Manager
- J. P. Albers,' Health Physics Engineer
- H. C. Marsh, Health Physics Manager (Acting)
- C. A. Kergis, Operations, Quality Assurance Engineer D. Pilmer, Manager, Nuclear Engineering and Safety
- +D. B. Schone, Project QA Supervisor, Units 2/3
- +R. Rosenblum, Supervisor, Construction & T/S Engineering W. G. Frick, Chemistry Supervisor
- F. Briggs, Compliance Engineer
- P. King, QA Supervisor, Operations K. Slagle, Startup Engineer G. Holloway, Supervisor, Startup Engineer
+R. Dietch, Vice President, Nucelar Engineering & Operations
+J. G. Haynes, Manager nuclear Operations
+G. Morgan, Station Manager, Operations
+M. Medford, Manager, Songs 2&3 Licensing Bechtel Power Corooration
- +J. R. Purucker, Professional Engineer
- S. H. Fried, Professional Engineer D. Hansen, Professional Engineer, Senior Member Allen Nuclear Associates, Inc. (ANA, Inc)
- L. Reynolds, Radiation Protection Engineer
+W. D. Allen, Radiation Protection Engineer
- Denotes those present at exit interview held on January 29, 1982.
+ Denotes those present at meeting; held at Region V Office on February 8, 1982.
In addition to the individuals noted above, the inspectors held conference calls with SCE and NRR (ETSB, RAB) personnel on February 4, 5, and 8,1982 and met with and interviewed other members of the licensee's and contractors
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staff at the site and at the NRC Regional Office on February 8,198 < -
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General Discussion The purpose for the inspection was t that is consistent with the Technand readiness for implem was concentrated on the status of: issuance of an Ope a
on protection 0.L.).
The focus of the inspection
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prior to
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procedures and training governing theImplement n
onitorin se systems.g Systems and b.
Implementation of a Radiological Envi required by Section 3/4.12 of the T Sronmental Monitoring Prog c.
required by Section 6.14 of the T SImplementation
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e Dose Calculation Manual (0DCM)
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Section 6.13 of the T.S. Implementation of an approved Proc
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ess Control Program required by e.
environmental monitorinImplementation of a Quality Assura
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nce Program for effluent and Guide 4.15, Revision 1,g using the guidance in Re
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of the T.S.
ory
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Previous NRC concerns in regards t on 6.8.1.i
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IE Inspection Report o the above items are discussed in Regio inspection reports.
50-361/81-35 and previous Region V preoperationaln V, The site inspection of procedures, recor,ds, and discussions 29, 1982, included a ending on January
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(ETSB and RAB) personnel.
facilities at Unit 2.
Also included was a tour of the licwith th n examination the rad waste, containment and au ili Process and effluent monitoring s the tour.
ensee's x
to implement his program with resInspectio pect to items a through e abovee licensee by the NRC. discussed in paragraph 2 of Inspe ticonsisten oncept for a phase-in-approach c
on Report 50-361/81-35 safely implemented provided the 0 LThe NRC inspectors was approved
.. and T.S. were amended to clearlye p define specific conditions for i conclusion was based on:
mplementation of certain items This
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General Discussion The purpose for the inspection was to examine SCE's capabilities and readiness for implementation of a radiation protection program that is consistent with the Technical Specifications (T.S.) prior to issuance of an Operating License (0.L.).
The focus of the inspection was concentrated on the status of:
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Implementation of Process and Effluent Monitoring Systems and procedures and training governing these systems.
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Implementation of a Radiological Environmental Monitoring Program required by Section 3/4.12 of the T.S.
Implementation of an aoproved Off Site Dose Calculation Manual (00CM)
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required by Section 6.14 of the T.S.
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Implementation of an approved Process Control Program re7uired by Section 6.13 of the T.S.
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Implementation of a Quality Assurance Program for effluent and environmental monitoring using the guidance ~in Regulatory Guide 4.15, Revision 1, February 1979 as _ required by Section 6.8.1.i of the T.S.
Previous NRC concerns in regards to the above items are discussed in Region V, IE Inspection Report 50-361/81-35 and previous Region V preoperational inspection reports.
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The site inspection, ending on January 29, 1982, included an examination of procedures, records, and discussions with the licensee's staff and NRR (ETSB and RAB) personnel. Also included was a tour of the licensee's facilities at Unit 2.
Process and effluent monitoring systems located in the rad waste, containment and auxiliary buildings were observed during the tour.
Inspection findings revealed that the licensee was not fully prepared to implement his program with respect to items a through e above consistent with the T.S.'s unless the concept for a phase-in-approach discussed in paragraph 2 of Inspection Report 50-361/81-35 was approved by the NRC.
The NRC inspectors concluded that the phase-in-approach concept could be safely implemented provided the 0.L. and T.S. were amended to clearly define specific conditions for implementation of certain items. This conclusion was based on:
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January 29, 1982 exit interview.
An examination of SCE correspondence provided to the NRC Region.V
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office and NRR between the period of February 1-12, 1982.
Conference calls between SCE, NRR and NRC Region V Reactor Radiation
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Protection Section on February 4th, 5th and 8th, 1982.
Discussions from a meeting between SCE Management personnel
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denoted in paragraph 1 and the NRC staff at the Region V office on February 8,1982.
Conference calls between NRC, Region V and NRR (ETSB and RAB)
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between February 1 and 12, 1982.
All of the correspondence provided by SCE satisfactorily addressed NRC findings discussed at the January 29, 1982 exit interview and will be included as Enclosures 1 through 5 of this report.
Subsequently the T.S. and 0.L. were mod'ified to the satisfaction of SCE, NRR (ETSB and RAB) and NRC Region V staff. These modifications clearly define the conditions for implementation of items a through e above using the phase-in-approach concept.
With a few exceptions, th'e c'onditions established in the 0.L. and T.S. as a result of this inspection will require the licensee to fully implement items a through e -above prior to first exceeding 5% rated thermal power or sooner. The!exceptionsareasfollows;
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An enhanced system for continuous monitoring and sampling of the containment purge exhaust'directly from the purge stack shall be installed and operational prior to, startup following the first refueling outage.
In the interim,' the coritainment airborne monitor 2RT-7804-1 and associated sampling media,shall_ perform this function.
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Continuous sampling'(T.S. Table 4.11-1, Notatio'n C) provisions shall be operational. prior to January 1,1983. -In the interim,
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administrative controls for. composite sampling of continuous releases per T.S. Table 4.11-1, Table Notation b. -will be allowed, c.
Sampling of the Miscellaneous Waste Evaporator Condensate will not be required if the Condensate Monitor Tank Bypass Valve (SA1415-21/2"-200) is verified locked closed at least once per 31 day ~
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-4-Remaining conditions, for the most part are identified in Section 3/4.10.5,
"Special Test Exceptions", the 0.L. or in the applicable portions of Appendix "A" to the T.S.
Details sunmarizing the above are discussed in the subsequent sections of this report.
No items of noncompliance or deviations wert identified.
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Technical Specifications Surveillance Requirements ~
A review of Station Order S023-G-3, Revision 2, " Technical Specification Surveillance Reouirenents" was conducted during the inspection.
The purpose for the Station Order is to outline the surveillance requirements of the T.S. and to define the responsibilities and identify the applicable procedure for accomplishing the T.S. surveillances.
The inspection revealed that approximately 50% of the health physics related procedures listed in the station order were not yet issued at the time of this inspection. The inspection also revealed that some of the procedures were prepared prior to the issuance of the latest T.S. revision and were probably obsolete and/or outdated. Most of the procedures pertaining to process and effluent monitoring systems were not issued.
Discussions with the licensee's staff at the exit interview indicated that the Task Force (discussed in paragraph 9 of IE Inspection Report 50-631/81-35) would be responsible for issuing these. procedures. The schedule for issuing these procedures had been established to support the implementation of the involved monitoring systems using the phased-in approach concept. A schedule for preparation and issuing of these procedures was provided to the inspector. The schedule appeared acceptable.
The inspectors examined Chemical Procedure S023-III-1.6, Revision 2,
" Primary System Chemical Limits", dated 1 April 1981 during the inspection. This procedure was one of those listed in Station Order S023-G-3. The review of this procedure revealed an error existed in paragraph 6.1.4.
The Dose Equivalent Iodine-131 value of less than
< 6.5 millicuries per gram specified in this paragraph is not in agreement with Section 3/4.4.7.of the T.S. which requires the specific activity of the primary coolant be limited to less than $1.0 microcuries per gram Dose Equivalent ' Iodine-131. This was discussed at the exit interview.
The inspectors reviewed the procedure for and test' results of the
" Generic Tests" (G.T.).of the Unit 2 NMC Containment Airborne' Radiation Monitoring System. The G.T. consists of.10 individual modules for performing calibration and functional' checks that were consistent with the FSAR recuirements. The generic tests checked such items as:
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digital output circuit calibrations / functional verifications
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power supply
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modular count rate meter
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filter paper advance and check source drive circuits
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flow instrumentation
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Additionally, instrument and control loop verifications and isotopic standarizations were performed with this test procedure. The isotopic tests were performed on all three system channels (gaseous, particulate and iodine) using NBS traceable sources. The tests were performed in accordance with Section 11.5.2.1.5.2 of the FSAR using generally accepted methods and procedures comon to industry practice.
The licensee Task Force members'(discussed in paragraph 9 of the IE Inspection Report 50-361/81-35) stated that the calibration of the Containment Airborne Radiation Monitoring System (as well as other process and effluent monitoring systems) did not meet the requirements of TABLE NOTATION (2) of Table 4.3-8 of the T.S. and the requirements of R.G. - 4.15, Revision 1.
Table 4.3-8 requires the initial channel calibration of the monitoring system over its intended range of energy and measurement range.
Regulatory Guide 4.15, Revision 1 requires an enhanced calibration and quality assurance program.
New calibration procedures are being developed by SCE's Radiation Monitoring Task Force to perform an " enhanced calibration" that will be consistent with the T.S. and Regulatory Guide 4.15, Revision 1.
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" enhanced calibration" for process. and effluent monitoring systems will be imple'mented using the phased approach.
In the interim the data of initial vendor's calibration and system calibration performed on-site have been reviewed by qualified professionals and been determined to be adequate and consistent with the calibration requirements of the FSAR.
The NRC inspector was in agreement with this approach after discussions with SCE and NRR (ETSB & RAB) and reviewing the SCE correspondence discussed in Section 2 of this report.
The 0.L. and Appendix
"A" of the T.S.; in particular Section 3/4.10.5 of the T.S., were modified to clearly define the conditions associated with the implementation of the process and effluent monitoring systems using the-phase in approach.
No items of noncompliance or deviations were identifie..
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TMI Action Items
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The inspectors examined the licensse~~ status for implementation of certain TMI Action Plan Recuirements discussed in NUREG 0737, Items II.B.3 and II.F.1 and paragraph 6 of_IE Inspection Report 50-361/81-35. The inspection report identified that the licensee would fonnally request NRR approval to extend the' completion of these items.- The inspectors examined:
(a) a licensee's memorandum to NRR dated December 22, 1981, (b) SER, Supplement 4, and (c) conditions which were added to the 0.L.
The examiniation revealed that the approval for implementation of these items has been extended to prior to first exceeding 5% rated thermal power. Additionally, a similar approval for extended implementation of Sections 6.8.4.b, "In-plant Radiation Monitoring" programs and 6.8.4.d. " Post-Accident Sampling" program was graated. The conditions for implementation of the above items are clearly defined in the 0.L. and Appendix "A" to the Technical Specifications. The need for these extensions were discussed at the exit interview.
No items of noncompliance or deviations were identified.
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Radiological Environmental Monitoring Program (REMP)
A meeting was held with SCE management on January 26, 1982 to discuss the implementation of a REMP that will be consistent with Sections 3/4.12 and 6.8.1.1 of the T.S..
Also discussed where the concerns with the REMP identified in paragraph 5 of.IE Inspection Report 50-351/81-35.
The discussions revealed that the licensee had prepared an action plan for upgrading the REMP at Units 2/3 to ensure compliance with the T.S. requirements. The plan also provides for a. systematic upgrading
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of the REMP currently in effect at Unit 1.
An SCE corporate office group has been designated the responsibility for implementation of the REMP.
Implementation of a REMP that will be in full compliance with the T.S. is not expected to be completed until prior to first exceeding 5% rated thermal power or July 1,1982, which ever comes earlier.
SCE has submitted a formal request to NRR and NRC's Region V Office asking for relief for implementation of the Interlaboratory Comparison program specified in Section 3/4.12.3 and for implementation of the
Quality Assurance Program specified in Section 6.8.1.1 of the T.S..
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.The request was reviewed and deemed acceptable by NRR (ETSB and RAB) and the NRC Region V staff.
Specific conditions authorizing the reffef have been clearly defined in the 0.L. and Appendix "A" of the T.S..
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No items of noncompliance or deviations were identified.
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Implementation of Process and Effluent Monitorina Systems The inspectors conducted a tour of the Unit 2 facility for the purpose of observing the status of process'and effluent monitoring systems.
Concerns that could affect the implementation of process and effluent monitoring systems consistent with the T.S. which. were identified from previous inspections and this tour were discussed with the licensee.
The concerns were discussed in detail with the Task Force and at the exit interview. Also discussed were items that interfaced with the implementation _of process and effluent monitoring systems. The need for obtaining satisfactorily resolutions for each concern and/or item identified prior to issuance of an OL was stressed during the discussions.
The following concerns / items were discussed:
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The environmental qualification of the Containment Area High Range Monitors.
b.
The ability of the NMC and GA monitoring systems to meet ANSI-N13.1,
" Guide to Sampling Airborne' Radioactive Materials'in Nuclear Facilities" due to the long samoling lines and numerous right angle bends and mechanical fittings on the sampling skids.
c.
Whether particle deposition and_ heat tracing engineering evaluations-were accomolished for all of th'e process and effluent monitoring systems.
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Schedules for completion of' SAI particle deposition', studies.
The necessity to h'ea't trace the' time Plant Vent Stacli Airborne e.
Monitor had not bend resolved.
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Whether the Unit ' condensation problem associated with the GA wide range monitor wGs, also applicable to Unit 2/3 GA monitoring systems.
The condensation problem with the Unit 1 ' wide range monitor was reported to Region V by the licensee. The reoort identified that the problem existed even though the sampling lines 'were heat traced.
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The acceptability of the Containment Airborne Monitor to meet the
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T.S., Table 3.3-13 reauirement for monitoring the containment purge.
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The method for accomolishing continuous sampling of the containment purge, plant and vent condenser evacuation system as required by the
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Information regarding the acceptability of the process and effluent monitoring system initial calibration and the method and schedule for*
accomplishing the enhanced calibrations.
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Preparation and issuance of procedures for performing T.S.
channel calibrations, channel functional checks, source checks and other T.S. surveillances.
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Training of personnel in the use of and requirements -for process and effluent monitoring systems and the Radioactive Effluent Monitoring Program.
The above concerns were also discussed with NRR (ETSB and RAB) personnel as identified in Section 2 of this report. Additionally, the licensee had provided the NRC with the correspondence (Enclosures 1 through 5)-
discussed in Saction 2 of this report. The discussions and correspondence satisfactorily addressed the above concerns and as a result the 0.L. and T.S. were subsequently modified as discussed in Section 2 of this report.
Concerns not included as conditions in the 0.L. and T.S. were resolved by discussions and in the licensee's correspondence provided to the inspectors.
No items of noncompliance or deviations were identified.
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Radiological Effluent Monitoring Program The inspectors reviewed Chemical Procedure S0123-III-5.0, Revision 0,
" Effluent Monitoring Program" and met with the effluent engineer discussed in Section 3 of IE Inspection Report 50.361/81-35.
Procedure S0123-III-5.0 defines the Radioactive Effluent Monitoring Program. The program has been assigned to the Supervisor of Plant Chemistry for establishing procedures for monitoring, sampling and analysis and record keeping. required for liquid and airborne radioactive waste releases. The effluent engineer has been assigned the responsibility for implementation of the Effluent Monitoring program.
Discussions were held with the Effluent Engineer and a review of a schedule he had prepared for imolementation' of the Effluent Monitoring Program was conducted. The discussions revealed that the scheduled implementation of the pr.ogram was well defined. ' ilmplementing procedures and training were expected to be complete by February 19, 1982.
The establishment of this program appeared to be emerging in an orderly, process due to the efforts of the effluent engineer.
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No items of noncompliance or deviations were identified.
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Licensee Action on IE Circulars IEC 81-09, Containment' Effluent Water that Bypasses Radioactivity a.
Monitor.
The licensee's evaluation adequately addressed the concerns of the circular.
The eval'Jation concluded that all possible liquid effluent release paths were being monitored. This matter is considered closed.
(IC-81-09).
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Licensee Actions on~ Previous Inspection Findings A question raised in paragraph 8 of IE Inspection Report 50-361/81-35 concerning the possible leakage of Quick Disconnects (Q.D.'s) associated with the NMC Plant Vent Stack tionitor was evaluated by the licensee.
The inspector examined the licensee's evaluation report. The report identified that the type of Q.D. used has a proven performance record -
and of greater significance is the fact that the Q.D. location is on the negative side of the pumo so that any failures causing leakage would be inward. The licensee was informed that the evaluation adeouately addressed the question which was raised.
No items.of noncompliance or deviations were identified.
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Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the site inspection on January 29, 1982.
The inspectors summarized the scope and findings of the inspection. The licensee w.is informed that there were no apparent items of noncompliance or deviations. The inspectors discussed the concerns summerized in Sections 2, 3, 4, 5, 6 and 7 of this report. The' inspectors commended the.
efforts of the Effluent Engineer.
Strong management effort was committed in response to resolving the concerns identified by the inspectors.
At the licensee's request, a management meeting was held in Region V office on February 8, 1982 to discuss the progress and status of open items impending before the issuance of the operating license.
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